Home Highlights October 2012 Year 2012 This

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1. Transfer pricing adjustment - when a quasi Judicial Authority like the DRP deals with lis u/s 144C then it is obligatory on its part to ascribe cogent and germane...

2. Transfer pricing - Order of Dispute Resolution Panel (DRP) - Non-speaking order - when a quasi judicial authority deals with a lis, it is obligatory on its part to...

3. Disciplinary proceedings against formerly Appellate Deputy Commissioner - If the order passed by the quasi judicial authority is taken as a foundation for bringing the...

4. TP Adjustment - Reference to TPO - none of the two conditions enshrined in the Instruction of 2016 were satisfied in as much as neither transfer pricing adjustment of...

5. Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

6. TP adjustment on interest on advances given to AEs - LIBOR + 260 basis points - the transactions of loans advanced to AEs by the assessee was adequately demonstrated by...

7. TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

8. Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

9. Transfer pricing adjustments - Arm’s Length Price - The arbitrary selection of comparables has in fact inflated the operating profit in the computation made by the...

10. Transfer pricing - Application of Section 144C - eligible assessee - Appellant contended that as the TPO has not prescribed any adjustment in the Transfer Pricing order....

11. Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

12. Audit Objections – relevance in making re-assessments - The function of the audit is essentially executive in nature, while the function of the assessing officer and his...

13. TP Adjustment - applicability of Section 144C(13) - As provided in the Section 144C(13) of the Act, the final order of the Assessing Officer should be in conformity with...

14. Misue of high positions of “Commissioner” - Provisional release of seized goods - It seems that the Additional Commissioner, while passing this order has not acted as...

15. Transfer pricing - Addition in final assessment - AO is not permitted to make any addition which is not contained in the draft assessment order and approved by the DRP u/s 144C